|From:||Lenny Siegel <firstname.lastname@example.org>|
|Date:||Thu, 17 Nov 2011 08:24:45 -0800 (PST)|
|Subject:||[CPEO-MEF] REGULATION: DOE Inspector General questions Federal Facilities Agreements|
My personal history with the challenges of funding the cleanup of
Federal Facilities began in 1991, with my participation in what
became the Federal Facilities Environmental Restoration Dialogue
Committee (FFRDC). The approach laid out in the FFRDC Final Report
still serves as the guide to resolving the challenges of meeting the
requirements of Federal Facilities Agreements at the Defense and
Energy Department in the fact of insufficient appropriations. In
general, the FFERDC solution still works.
Now, buried in an over-arching review of Energy Department “Management Challenges,” the DOE Inspector General suggests returning to where we were in 1991, recommending:
"To ensure that risk drives funding choices and priorities rather than potential local or regional influences, the Department should retain a respected outside group, such as the National Academy of Sciences, to rank and rate, on a national, complex-wide risk/priority basis the Department's environmental remediation requirements."
This recommendation ignores the key role that federal, state, and in some cases tribal regulators, as well as impacted communities, must play in the cleanup of the nuclear weapons complex. Re-organizing the program around a centralized "risk list" is likely to heighten confrontation without improving cleanup "on the ground" or under it. Furthermore, the Inspector General exaggerates the nature of the problem by including all Environmental Management funding in its description of the problem. While the long-term management of nuclear wastes at Energy site is a big deal, it is different from the challenge of soil and groundwater remediation, which by itself has a much lower price tag.
- Lenny Siegel Management Challenges at the Department of Energy Department of Energy Office of Inspector General DOE/IG-0858 November 2011 Page 10 (page 11 of the PDF)Reprioritize the Department's Environmental Remediation Efforts on a Complex-wide Basis Utilizing a Risk-Based Strategy – Fund Only High Risk, High Priority Activities
BackgroundThe Department's current unfunded environmental remediation liability is approximately $250 billion. The result of more than 50 years of nuclear defense and energy research work, this effort involves 2 million acres of land located in 35 states and employs more than 30,000 Federal and contractor employees. The Department spends about $6 billion per year on its environmental remediation activities. In doing so, program costs are largely "driven" by 37 individually negotiated Federal Facility Agreements (FFA) at key Department sites across the Nation. The FFAs involve no less than 350 milestones at these sites. The FFAs are augmented by numerous other local agreements with their own set of actions, requirements, milestones and due dates.
IssueThe FFAs and related requirements are the result of individual, site- specific negotiations between the Department and Federal and state regulators. In many cases, these agreements were reached after complex, painstaking negotiations over many years. In some cases, the courts are also involved in these agreements. Modifying these agreements would be a very costly and time- consuming process and would, understandably, be extremely unpopular with a variety of constituencies. However, the current strategy may not be sustainable if the Department's remediation budget suffers major reductions.
Key Question: Are the Department's existing environmental remediation commitments sustainable in light of current budget realities and, as a corollary, would a risk-based strategy applied throughout the complex allow for improved targeting of scarce remediation resources?
Path ForwardThe Department should consider revising its current remediation strategy and instead address environmental concerns on a national, complex-wide risk basis. This would result in a form of environmental remediation triage. Looking at the program holistically, fund only high risk activities that threaten health and safety or further environmental degradation. Consistent with this philosophy, where appropriate and consistent with U.S. Environmental Protection Agency guidance and long term Department land-use planning policies, reduce costs by remediating to "brownfield" rather than "greenfield" standards.
To ensure that risk drives funding choices and priorities rather than potential local or regional influences, the Department should retain a respected outside group, such as the National Academy of Sciences, to rank and rate, on a national, complex-wide risk/priority basis the Department's environmental remediation requirements. The Department's National Integrated Priority List could serve as a logical starting point for this exercise.
-- Lenny Siegel Executive Director, Center for Public Environmental Oversight a project of the Pacific Studies Center 278-A Hope St., Mountain View, CA 94041 Voice: 650/961-8918 or 650/969-1545 Fax: 650/961-8918 <email@example.com> http://www.cpeo.org_______________________________________________
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